Description of Firm Pathway Partners Wealth Advisors, LLC is a registered investment adviser based in Amherst, NY. We are organized as a limited liability company ("LLC") under the laws of the state of New York. We are owned by Colin Healy, John A. Bruno Jr., and Joseph R. Bruno Jr. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Pathway Partners Wealth Advisors, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Portfolio Management Services Our services begin with us collecting information about your goals, objectives and financial situation in order to provide financial planning and consulting that covers a number of topics, including but not limited to retirement, education, estate planning, insurance and tax advice, and advice on how to accomplish your financial goals. We offer discretionary portfolio management services tailored to meet your client needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Initial and ongoing financial planning and consulting is provided to portfolio management clients at no additional cost. As part of our portfolio management services, we may use one or more third party money managers to manage a portion of your account on a discretionary basis. The third party money manager(s) may use one or more of their model portfolios to manage your account. We will regularly monitor the performance of your accounts managed by third party money manager(s), and may hire and fire any third party money manager without your prior approval. We may pay a portion of our advisory fee to the third party money manager(s) we use; however, you will not pay our firm a higher advisory fee as a result of any third party money manager relationships. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by an unaffiliated investment managers, which are available through a single contract advisory platform, such as Envestnet, Inc., that integrates the services and software used by financial advisors in wealth management. The model portfolios are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that

can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Financial Planning Services Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning. Financial Planning services are included as a complementary part of our procedures in onboarding new clients and periodically with existing clients to ensure investment portfolios meet the client’s needs/goal. However, we reserve the right to charge a fee for financial planning if the client will only utilize us for that service alone (See Item 5 below). Types of Investments We offer advice on equity securities, certificates of deposit, municipal securities, variable life insurance, variable annuities, mutual fund shares, United States government securities, money market funds, REITs, structured products, ETFs and interests in partnerships investing in real estate. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. IRA Rollover Recommendations For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Wrap Fee Programs We do not participate in any wrap fee program. Assets Under Management Pathway Partners Wealth Advisors, LLC has $ 34,333,672.00 discretionary assets under management as of December 2023.